In absence of liability to pay advance tax, Interest U/s. 234B not applicable

DCIT Vs. M/s Master card International Inc (ITAT Delhi) Solitary issue raised by the Revenue is against the decision of the Ld. CIT(A) in holding that interest u/s.234B is not leviable in respect of payments to the non-resident assessee, being subject to tax deduction at source u/s. 195 of the Act. We find that the issue has been decided in favour of the assessee by the Hon’ble Delhi High Court, in earlier assessment years, in assesee’s own case. Further, the Ld. CIT(A) in assessee’s own case for AY 2005-06 and 2008-09 in Appeal nos. 160 and 162/10-11 vide order dated 14.2.2013, decided ...